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GAO-02-746R: 

United States General Accounting Office: 
Washington, DC 20548: 

July 18, 2002: 

The Honorable Charles O. Rossotti: 
Commissioner of Internal Revenue: 

Subject: Management Report: Improvements Needed in IRS's Accounting
Procedures and Internal Controls: 

Dear Mr. Rossotti: 

In February 2002, we issued our report on the results of our audit of 
the Internal Revenue Service’s (IRS’s) financial statements as of, and 
for the fiscal years ending, September 30, 2001, and 2000, [Footnote 1] 
and on the effectiveness of its internal controls as of September 30, 
2001. We also reported our conclusions on IRS’s compliance with
significant provisions of selected laws and regulations and on whether 
IRS’s financial management systems substantially comply with 
requirements of the Federal Financial Management Improvement Act of 
1996. A separate report on the implementation status of recommendations 
from our prior IRS financial audits and related financial management 
reports will be issued shortly. 

The purpose of this report is to discuss additional matters identified 
during our fiscal year 2001 audit regarding accounting procedures and 
internal controls that could be improved. These matters are not 
considered material in relation to the financial statements; however, 
they warrant management’s consideration. 

Results in Brief: 

During fiscal year 2001, IRS had a number of internal control issues 
that affected financial reporting, including safeguarding of assets. 
These issues concern policies and procedures over (1) receipt of 
taxpayer payments, (2) courier services that transport taxpayer data, 
(3) employee fingerprint records, (4) issuance of manual refunds, (5) 
release of tax liens, (6) recording of property and equipment (P&E)
transactions, (7) linking of property and accounting records, (8) 
software licenses, (9) reimbursable receivables, [Footnote 2] and (10) 
recording changes in administrative account balances. 

Specifically, we found the following: 

* IRS did not have adequate controls over taxpayer payments received at
certain field locations. We found that (1) although receipts were 
usually issued, notices reminding taxpayers to obtain receipts for 
payments were not present, (2) at two field office locations, payments 
placed in drop boxes were processed by only one employee, and (3) 
payment logs were not reconciled to taxpayer documents. As a result, 
IRS’s risk of theft, loss, or misuse of taxpayer deposits was 
increased. 

* IRS service center campuses did not ensure that couriers had undergone
background checks. As a result, IRS’s risk of theft, loss, or misuse of 
deposits and taxpayer information was increased. 

* IRS’s database to track fingerprint results was subject to technical 
constraints and human error. These issues resulted in numerous 
instances of erroneous or missing data. Incomplete and inaccurate 
fingerprint data may hamper IRS’s investigations of security 
violations. 

* IRS staff did not always perform or document required monitoring of
manually processed tax refunds. As a result, the risk that other staff 
or IRS’s automated tax system could issue duplicate refunds was 
increased. 

* IRS did not record the dates on which certificate of lien releases 
were mailed to courts and we noted long delays between the date of the 
IRS certificate of lien release and the date the local jurisdiction 
recorded its receipt. Delays in releasing tax liens could cause undue 
hardship and burden to taxpayers who are attempting to sell property or 
apply for commercial credit. 

* IRS did not follow procedures for promptly recording assets on its 
property management system, resulting in delays in the proper 
accounting for hundreds of P&E items, such as microcomputers. 

* IRS’s asset acquisition costs on the accounting records could not 
always be linked to assets recorded on the inventory records. 
Consequently, the existence of certain property acquired and recorded 
on accounting records during fiscal year 2001 was not verifiable. 

* IRS’s property management system did not maintain an inventory of 
software or software licenses. As a result, IRS could not determine its 
compliance with software licenses or effectively account for and manage 
acquired software. 

* IRS did not adequately monitor and review reimbursable receivables to
determine their validity or collectibility. As a result, certain amounts
recorded as reimbursable receivables reported on IRS’s financial 
statements were not valid or were uncollectible. 

* IRS did not have procedures to estimate and accrue material changes in
administrative account balances throughout the fiscal year. The lack of 
these procedures going forward may preclude IRS from having assurance 
that interim financial statements it is required to prepare for fiscal 
year 2002 per the Office of Management and Budget (OMB) Bulletin 01-09, 
Form and Content of Agency Financial Statements, are reliable. 

At the end of our discussion on each of these issues, we offer 
recommendations for strengthening IRS’s internal controls. 

In its comments, IRS agreed with our recommendations and described 
actions it was taking or had planned to address several of the control 
weaknesses described in this report. At the end of our discussion of 
each of the issues in this report, we have summarized IRS’s related 
comments and provided our evaluation. We also considered IRS’s feedback 
on our findings and have made revisions as appropriate. 

Scope and Methodology: 

As part of our audit of IRS’s fiscal years 2001 and 2000 financial 
statements, we evaluated IRS’s internal controls and its compliance 
with selected provisions of laws and regulations. We designed our audit 
procedures to test relevant controls and included tests for proper 
authorization, execution, accounting, and reporting of transactions. 

We conducted our audit in accordance with U.S. generally accepted 
government auditing standards. Further details on our scope and 
methodology are included in our February 2002 report on the results of 
our fiscal years 2001 and 2000 financial statement audit. [Footnote 3] 
We requested comments on a draft of this report from the Commissioner 
of IRS or his designee. We received written comments from the Deputy 
Commissioner and have reprinted the comments in enclosure I to this 
report. 

IRS Needs to Strengthen Controls Over Taxpayer Receipts: 

During our fiscal year 2001 financial audit, we identified several 
issues related to IRS’s controls over taxpayer receipts that increased 
the risk that such receipts could be lost or stolen and that the theft 
would not be timely detected. GAO’s Standards for Internal Controls in 
the Federal Government requires agencies to establish controls to 
safeguard valuable assets and reduce the risk of error or fraud. The
standards state that such controls should include 1) periodic 
comparisons between resources and records to ensure proper 
accountability and 2) segregation of duties so that no one individual 
controls all aspects of a transaction. 

In prior audits, we had noted weaknesses in IRS’s physical controls 
over service center campus and field office taxpayer receipts. 
[Footnote 4] We recommended that IRS (1) establish procedures to 
provide receipts to walk-in taxpayers [Footnote 5] at IRS service 
center campuses regardless of the method of payment, and (2) post signs 
at the campuses to remind taxpayers to ask for receipts. We also 
recommended that IRS record remittances made by walk-in taxpayers in 
control logs prior to depositing them in a locked container, and that 
IRS reconcile the control log information to the tax receipts prior to 
processing. As a result of our recommendations, IRS issued guidance in 
1999 and updated its procedures in 2000 on controls over receipts. 
Specifically, these procedures required IRS to (1) post signs in all 
service center campus lobbies to remind taxpayers to request a receipt, 
(2) record payments made by walk-in taxpayers on control logs, and (3) 
establish segregation of duties for recording and reconciling taxpayer 
receipts. 

During our fiscal year 2001 audit, we found that service center 
campuses no longer accepted walk-in payments, but rather directed 
taxpayers to field offices. At the field offices we visited, we found 
that although IRS employees usually issued a receipt for walk-in 
payments, IRS had no policy requiring that field offices issue a 
receipt for all payments. Additionally, IRS had no requirement that 
signs be posted in field office lobbies to remind taxpayers to request 
receipts. One field office we visited had not posted such signs. The 
issuance of receipts for all payments, followed by timely and thorough 
management reviews of receipts issued, provides better accountability 
for walk-in payments received by IRS. 

Additionally, we found control issues related to drop boxes maintained 
at field offices for walk-in taxpayers to deposit payments. At each of 
the two offices we visited, we found that only one employee emptied the 
drop box and recorded the payments on a log. At one of the offices, the 
same employee later reconciled the payments to the log. Requiring two 
employees to retrieve and record payments from drop boxes establishes 
better control and accountability for these receipts. However, IRS 
currently does not have a policy requiring dual control over drop box 
receipts. Additionally, IRS did not provide adequate oversight to 
ensure that its employees adhered to its policy regarding segregation 
of duties over the reconciliation of receipts. This increases the risk 
of theft of taxpayer payments. 

IRS did not have policies/procedures to reconcile receipts found during 
final candling to the final candling log. [Footnote 6] As a result, we 
found that two IRS service center campuses and one of two lockbox banks 
[Footnote 7] we visited did not reconcile receipts found during final 
candling to the candling logs. At the lockbox bank, we noted that two 
separate logs were used to record checks found during final candling. 
Employees performing final candling recorded only the number of checks 
found on the initial log while a supervisor prepared a second more 
detailed log several hours later that identified the taxpayer and the 
amount of the check. However, the supervisor did not reconcile the 
number of checks indicated on the initial log with the checks on hand. 
Consequently, bank managers were unable to explain differences we noted 
between the number of checks on the initial log and the detailed log. 
The failure to maintain adequate control logs of all checks found 
during final candling increases the risk that not all checks will be 
accounted for and eventually credited to taxpayers’ accounts. 

Recommendations: 

We recommend that you direct IRS management to develop policies and 
procedures to require that: 

* field office employees provide taxpayers receipts for all walk-in 
payments; 

* field offices post signs in the most visible locations to remind 
taxpayers to obtain receipts for payments; 

* two employees be present when payments are collected and logged from 
drop boxes; 

* IRS and lockbox employees performing final candling record receipts 
in a control log at the time of discovery, recording at a minimum the 
total number of payments found, the amount of each payment, and the 
taxpayer who submitted the payment; and; 

* IRS and lockbox managers or designated officials reconcile logs of 
payments found during final candling to the related receipts and 
documents. 

We also recommend that you direct IRS headquarters management to ensure 
that field office management comply with existing receipt control 
policies that require a segregation of duties between employees who 
prepare control logs for walk-in payments and employees who reconcile 
the control logs to the actual payments. 

IRS’s Comments and Our Evaluation: 

In its comments, IRS noted that it had taken several actions to address 
this finding. Specifically, IRS stated that it (1) revised signs and 
posted them in all Taxpayer Assistance Centers or field offices 
notifying taxpayers that they may request a receipt, (2) distributed to 
Taxpayer Assistance Center sites or field offices a procedural memo 
outlining separation of duties to emphasize the need to have more than 
one employee process drop box payments, and (3) established a task 
force to develop procedures to reconcile payment logs. We will evaluate 
the effectiveness of IRS’s efforts during our fiscal year 2002 
financial audit. 

IRS Needs Better Enforcement Of Courier Service Policy: 

During our fiscal year 2001 audit, we found that IRS did not have 
effective controls in place to ensure that new courier service 
requirements were enforced. Since November 1998, we reported that IRS 
did not have effective controls over courier services responsible for 
transporting taxpayer receipts. [Footnote 8] This increased IRS’s risk 
of theft, loss, or misuse of deposits and taxpayer information. We 
recommended that IRS develop policies to ensure that contracts related 
to courier services do not unduly expose the government or taxpayers to 
losses in the event of lost, stolen, or damaged deposits in transit. In 
response, IRS issued courier service standards that require that 
courier service employees pass a limited background investigation. 

During our fiscal year 2001 audit, we identified weaknesses in IRS’s 
enforcement of its courier service standards. Specifically, at the two 
IRS service center campuses we visited, we found that background checks 
for couriers were not performed or were performed too late. At one 
campus, managers did not believe a background check was required 
because their couriers did not physically enter the campus facility and
the courier policy only required couriers given access to campus 
premises to pass a background check. The courier policy limits 
background check requirements to couriers given access to campus 
premises. However, to better protect the government and taxpayers 
against theft and losses, background checks should be performed on IRS 
couriers entrusted with deposits because they are given access to the 
deposits, which contain taxpayer data. Managers at another campus 
understood the intent of the courier policy and obtained background 
checks for its couriers even though they did not enter campus premises. 
However, the background checks for these couriers were not performed 
prior to entrusting them with deposits and taxpayer data because campus 
managers did not know how to initiate the background check process for 
couriers and did not know who was responsible for ensuring that this 
process was performed. As a result, fingerprints and background 
investigations on the couriers were not initiated until the latter part 
of fiscal year 2001. This increased IRS’s risk of theft, loss, or 
misuse of deposits and taxpayer information. 

Recommendation: 

To ensure that service center campus management and the courier service 
meet the intent of minimum courier policy requirements, we recommend 
that you direct IRS headquarters management to clarify that the 
requirement for background investigations is meant to apply to 
personnel being entrusted with taxpayer receipts and information, 
rather than just personnel being granted access to an IRS facility. 

IRS’s Comments and Our Evaluation: 

IRS agreed that courier service employees should undergo background 
checks. IRS noted it is working with FMS to modify courier service 
contracts and is amending the IRM to require the courier service to 
satisfy requirements for a basic investigation, which includes a 
Federal Bureau of Investigation (FBI) fingerprint and name check. We 
will evaluate the effectiveness of IRS’s efforts during our fiscal year 
2002 financial audit. 

IRS Needs to Work With The National Finance Center To Correct 
Fingerprint System: 

During our fiscal year 2001 financial audit, we identified problems 
with the integrity of certain information in a key database system IRS 
uses to track compliance with its employee fingerprinting requirement. 
Specifically, we found numerous instances of missing or erroneous data 
in the National Finance Center’s (NFC) Security Entry and Tracking 
System (SETS) database. According to IRS staff, these problems are due 
to both technical limitations in SETS and human error. Tracking 
fingerprint results provides an important internal control for IRS to 
prevent the hiring of applicants with inappropriate backgrounds. 

In response to issues we raised in previous audits concerning physical 
security of taxpayer receipts and data, IRS issued a directive in April 
2000 that prohibited the hiring and placement of an applicant at any 
IRS location until the applicant’s fingerprint check had been received 
and case disposition evaluated. An IRS memorandum issued April 23, 
2001, provided guidance on monitoring IRS’s background investigation 
program, including fingerprint results. The memorandum states, “It is 
critical to the integrity of the system that the information entered in
SETS is timely and accurately entered.” Based on the guidance, IRS 
officials are required to review a SETS report that tracks records that 
have missing fingerprint results or that indicate employees began work 
before their fingerprint results were received. The officials are 
required to follow up on these records, and update the SETS system 
accordingly. 

Our analysis of over 20,500 employee records in the SETS system 
identified 411 records with missing or erroneous data. Specifically, 
there were 231 employee records with blank fields for the date 
fingerprint results were received and 180 employee records where the 
dates the fingerprint results were received were earlier than the dates 
the fingerprint checks were completed per information from the Office
of Personnel Management (OPM). SETS data for 42 of the 180 employee 
records showed that the employees entered on duty after fingerprint 
results were received, while OPM data indicated that fingerprint 
results were not provided by OPM until after the employees began 
working at IRS facilities. 

According to IRS officials, many of these discrepancies are due to 
technical constraints within SETS. For example: 

* SETS did not always retain data fields when a person’s status was 
changed from applicant to employee. 

* The SETS database allows only one record or line entry per employee or
social security number. Therefore, when subsequent 
fingerprint/background results are received and entered, SETS 
eliminates the initial fingerprint record and replaces it with the new 
data. 

* The “enter-on-duty” dates for seasonal employees are “locked” in SETS 
for a period of time. When subsequent fingerprint checks are processed, 
the SETS system will show the most recent date that these subsequent 
fingerprint checks are initiated and completed. However, the system 
will not allow a change to the enter-on-duty date until the seasonal 
employee actually returns to IRS employment. 

Additionally, IRS officials indicated that in some instances human 
error contributed to missing or erroneous information in SETS. Because 
of the constraints of the SETS system, staff were using local tools for 
spreadsheet analysis to ensure that missing or misleading information 
was researched and pertinent data annotated accordingly, so that the 
local hiring and personnel officials could address questions regarding 
missing or erroneous information. 

Because of the data integrity issues with respect to certain 
information in the SETS database, IRS’s national office cannot 
effectively monitor servicewide compliance with its employee 
fingerprinting requirement. This increases the risk that employees
without fingerprint results may have unsuitable backgrounds to handle 
cash, checks, and sensitive taxpayer information, thus increasing the 
risk of potential theft and for misuse of proprietary taxpayer 
information. 

Recommendation: 

We recommend that you direct IRS management to work with the NFC to 
resolve the technical limitations that exist within the SETS database 
and continue to periodically review SETS data to detect and correct 
errors. 

IRS’s Comments and Our Evaluation: 

In commenting on this section, IRS stated that it will work through the 
Department of the Treasury in establishing a dialogue with NFC to 
address SETS issues. IRS also stated that it had recently trained its 
personnel on analyzing SETS data to ensure its accuracy and compliance 
with IRS’s fingerprint policies. We will evaluate the effectiveness of 
IRS’s efforts during our fiscal year 2002 financial audit. 

IRS Needs to Ensure Compliance With Manual Refund Procedures: 

During our fiscal year 2001 audit, we found that IRS staff did not 
always comply with the agency’s procedures designed to reduce the risk 
of issuance of duplicate refunds. In our prior audits of IRS’s 
financial statements, we identified and reported weaknesses in IRS’s 
controls over manual refunds that resulted in instances in which IRS 
issued duplicate refunds to taxpayers. [Footnote 9] This situation 
occurred because IRS’s (1) automated and manual refund processes are 
not adequately coordinated to prevent duplicate refunds, [Footnote 10] 
(2) manual refunds bypass most of IRS’s automated validity checks, and 
(3) manual refunds may not be recorded in the taxpayer’s account until 6
weeks after the refund has been issued. 

In response to our findings, IRS implemented a series of written 
procedures to reduce the risk of issuing duplicate refunds. These 
procedures require employees initiating a manual refund to (1) monitor 
the taxpayer’s master file [Footnote 11] account until the refund is 
recorded in the account, and (2) document their monitoring actions on 
case history sheets. The procedures also require that supervisors 
review the initiator’s monitoring actions and document this review. By 
monitoring the taxpayer’s master file account, the employee can detect 
the recording of subsequent computer-generated or other manual refunds 
and take action to stop duplicate refunds from being issued.
Documenting the monitoring action allows supervisors to verify and 
ensure that the monitoring is being performed. 

In our fiscal year 2001 financial audit, we found that IRS personnel 
were not always following IRS’s manual refund procedures. Specifically, 
we found that employees initiating manual refunds did not always 
monitor accounts or document their monitoring actions, and that 
supervisors did not always review the initiator’s monitoring actions. 
At the two service center campuses we visited, employees and 
supervisors stated they were unaware of the agency’s manual refund 
requirements. At one of these campuses, local procedures required 
clerks, rather than the staff initiating the manual refund, to monitor 
accounts. However, the clerks did not document their monitoring 
actions, and supervisors did not review these actions. The failure to 
follow IRS’s refund monitoring procedures increases the risk that a
duplicate refund will be issued. 

Recommendation: 

We recommend that you direct IRS management to issue a formal reminder 
of existing IRS manual refund procedures to supervisors and staff. 

IRS’s Comments and Our Evaluation: 

In its comments, IRS noted that it sent a communication to all service 
center campuses and field offices requiring that the appropriate IRS 
division monitor all manual refunds to ensure that no duplicate refunds 
are issued and to ensure that manual refunds are recorded in the 
taxpayer’s account. IRS stated that this communication also required 
management to document their review. We will evaluate the effectiveness 
of IRS’s efforts during our fiscal year 2002 financial audit. 

IRS Needs Procedures to Track Status of Lien Releases: 

In previous audits and again during our fiscal year 2001 audit, we 
found that IRS did not comply with certain provisions of the Internal 
Revenue Code (IRC) regarding the timely release of federal tax liens. 
However, because IRS lacks procedures to adequately track the lien 
release process, neither we nor IRS were able to determine the full 
extent of the problem. The failure to promptly release tax liens could 
cause undue hardship and burden to taxpayers who are attempting to sell 
property or apply for commercial credit. 

The IRC grants IRS the power to file a lien against the property of any 
taxpayer who neglects or refuses to pay all assessed federal taxes. The 
lien becomes effective when it is filed with a designated office, such 
as a courthouse in the county where the taxpayer’s property is located. 
The lien serves to protect the interest of the federal government and 
serves as a public notice to current and potential creditors of the
government’s interest in the taxpayer’s property. For example, federal 
tax liens are disclosed in credit reports of individuals. Under Section 
6325 of the IRC, IRS is required to release a federal tax lien within 
30 days after the date the tax liability is satisfied or has become 
legally unenforceable or the Secretary of the Treasury has accepted a 
bond for the assessed tax. 

In our fiscal year 2001 financial audit, we tested a statistical sample 
of 59 tax cases with liens in which the taxpayers’ total outstanding 
tax liabilities were either paid off or abated during fiscal year 2001. 
We found 5 instances in which IRS’s Automated Lien System (ALS) 
[Footnote 12] clearly indicated that IRS had not released the 
applicable federal tax lien within the statutory requirement. Based on 
these 5 cases, we estimated that 8 percent of all liens were not 
released timely. [Footnote 13] However, we also identified 9 additional 
cases where the liens may not have been effectively released within the
required period. In these cases, the time between the date on the IRS 
lien release certificate and the date when the jurisdiction handling 
the lien stamped the form as received exceeded 30 days, in some 
instances substantially. For 5 of these 9 cases, the period between the 
date on IRS’s lien release certificate document and the date of the 
receipt by the local jurisdiction exceeded 90 days. In 1 of these, the 
lien release was not recorded by the local jurisdiction until 9 months 
after the date on the lien release certificate. 

Currently, the only information IRS has to determine whether a lien was 
released timely is the date on the certificate of release of lien. 
However, this is the date on which ALS generates the document and does 
not necessarily represent the date when the authorizing IRS official 
signed it or when IRS mailed it to the local jurisdiction. IRS 
procedures currently do not require employees to track the status of 
lien releases up to the point of delivery to the local jurisdiction. As 
a result, both we and IRS were unable to determine whether delays took 
place at IRS, the local jurisdiction, or a combination of the two, and 
thus devise a strategy to address these delays. However, since the lien 
is not legally released until recorded by the local jurisdiction, these
delays could cause undue hardship and burden on taxpayers who want to 
sell property or apply for commercial credit. 

Recommendation: 

We recommend that you direct IRS management to establish procedures to 
track the release of liens up to the point of delivery to the local 
jurisdiction to ensure liens are released timely to avoid unduly 
burdening taxpayers once they have satisfied their tax liability. 

IRS’s Comments and Our Evaluation: 

In commenting on this section, IRS agreed that the failure to timely 
release liens could cause undue hardship and additional burden on 
taxpayers, and that existing procedures should be strengthened to 
include monitoring the mailing of certificates of release. While IRS 
noted that the timely release of liens also depends upon the United 
States Postal Service delivering the release to the recording 
jurisdictions within established timeframes and the jurisdiction 
recording the certificates of release promptly after receipt, IRS 
accepted responsibility for generating certificates of release and 
transmitting them to the appropriate recording official. To ensure it
accomplishes these actions within established timeframes, IRS stated 
that it is formulating procedures requiring a date stamp (mailing date) 
on the billing voucher, which lists each lien release IRS sends to the 
recording official. IRS stated it would also reemphasize to staff the 
importance of timely accomplishing all other lien processing steps. We 
will evaluate the effectiveness of IRS’s efforts during our fiscal year 
2002 financial audit. 

IRS Needs to Improve Procedures for Recording P&E Acquisitions On 
Inventory Records: 

During our fiscal year 2001 audit, we continued to find issues with 
IRS’s procedures for recording assets on its inventory records that 
inhibit IRS’s ability to properly account for and manage its assets. 
Specifically, we found that the P&E inventory did not always contain 
valid records. In addition, we found that assets were not always 
recorded promptly upon receipt. Accurate records are essential for 
maintaining control over P&E to ensure that assets are properly 
accounted for and safeguarded. 

While we noted progress in IRS’s efforts to promptly and accurately 
record P&E on its inventory records in fiscal year 2001, we nonetheless 
continued to find errors in IRS’s property records, the most 
significant of which were discussed in our recently issued report on 
the results of our fiscal year 2001 audit. [Footnote 14] In addition to 
the issues discussed in that report, we also found that 12 of 210 (6 
percent) randomly selected assets from the floor at 21 IRS facilities 
were not recorded on IRS’s inventory records. [Footnote 15] Of the 21 
buildings sampled, 7 (33 percent) had at least 1 asset in our sample of 
10 items that was not recorded on the inventory records. Items not 
recorded included a vehicle, a laptop computer, a microcomputer, and 
printers. While we were unable to determine the exact reason these 
specific assets were not recorded, IRS personnel at 4 other sites we 
visited stated that procedures for recording P&E acquisitions did not 
function adequately to ensure that assets were promptly recorded on 
inventory records. 

IRS’s procedures for recording P&E acquisitions provide that the IRS 
National Office create “due-in” or skeletal property records in its 
property management system based on information extracted from IRS’s 
procurement systems. The objective is to build an inventory template 
record with key information that Single Point Inventory Function (SPIF) 
personnel in the field offices can update upon receipt of the assets. 

Based on our work, we found that improvements are needed to fully 
achieve this objective. SPIF personnel at four sites where we conducted 
testing noted that the National Office did not always create skeletal 
inventory records prior to the receipt of assets. If a skeletal record 
was not available upon the receipt of an asset, recording the asset on 
the inventory records was delayed because procedures do not allow SPIF 
units to create an inventory record. Before an asset could be added to 
the inventory records, it was necessary for the SPIF unit to research 
IRS’s procurement system to identify requisition information and 
provide the information to the National Office with a request to create 
a skeletal asset record. As a result, delays occurred in recording some 
assets, and some assets were not recorded until they were discovered
by IRS personnel during an annual inventory. 

For example, at one site, 178 computers received on September 10, 2001, 
were not recorded on the inventory records until October 1, 2001, 
because a skeletal record was not available when the assets were 
delivered. SPIF units at the sites we visited discovered hundreds of 
unrecorded items, such as microcomputers and monitors, during the 
fiscal year 2001 inventory. Not only were skeletal records not available
when assets were delivered, but skeletal records were also initiated 
but not completed, resulting in invalid records. During our fiscal year 
2001 audit, we found 461 invalid property records on IRS’s inventory 
system because a skeletal record had been created but not completed. 
This reduces the reliability of the information maintained in the 
inventory system and impedes IRS management’s ability to control and 
account for federal property. 

Recommendations: 

We recommend that you direct IRS management to: 

* ensure that complete skeletal records are created and available for 
the SPIF units to update upon receipt of P&E, and; 

* develop procedures and edit checks to reduce the likelihood of invalid
property records. 

IRS’s Comments and Our Evaluation: 

In its comments, IRS stated that it agreed with our recommendations and 
is taking actions to address this issue. IRS stated that it is 
developing a system and procedures to create skeletal records and to 
ensure timely updates to inventory records. We will evaluate the 
effectiveness of IRS’s efforts during our fiscal year 2002 financial 
audit. 

IRS Needs to Improve Its Process for Linking P&E Acquisitions to 
Property Records: 

During our fiscal year 2001 audit, we found that asset acquisition 
transactions recorded on accounting records could not always be linked 
to assets recorded on the property records. The ability to link costs 
recorded on the accounting records to property records is essential to 
verify the existence of assets purchased. 

IRS’s property management system does not capture the acquisition cost 
of P&E. As a result, the property management system does not provide 
either the detailed subsidiary records to support the general ledger 
control balances or the detailed information needed for financial 
reporting. To compensate for this deficiency, IRS extracts the 
acquisition costs of P&E from expense records at fiscal year end and
accumulates the costs into pools of similar assets. Costs accumulated 
into asset pools are to be linked to assets recorded on the property 
records through IRS’s procurement systems using procurement award 
numbers and requisition numbers. 

However, we found that costs recorded in the accounting records could 
not always be linked to items recorded on the property records because 
the procurement award numbers and requisition numbers recorded on the 
property records were invalid or incomplete. 

Although IRS was eventually able to link a majority of the P&E 
acquisitions we selected for testing during our fiscal year 2001 audit, 
this process took 6 weeks to complete. Additionally, IRS was unable to 
link a number of the P&E acquisition items to the property records. 
Specifically, IRS was unable to link 4 of 17 P&E acquisition 
transactions we tested to the property records and could only partially
link the assets purchased in 3 other transactions. For example, IRS was 
able to link 90 of 180 computers purchased in 1 transaction to the 
property records. [Footnote 16] Consequently, the existence of all 
property acquired and recorded on the accounting records during fiscal 
year 2001 could not be verified. 

Recommendation: 

We recommend that you direct IRS management to develop procedures to 
ensure that procurement award and requisition numbers recorded on 
property records are complete, accurate, and linked to the accounting 
records. 

IRS’s Comments and Our Evaluation: 

In commenting on this section, IRS stated that it agreed with our 
recommendation. IRS noted that it is developing procedures and systems 
to capture more detailed information on property records and that this 
process will require vendors to include requisition and procurement 
numbers of equipment purchases at the time of shipment. IRS also noted 
that the full integration of inventory procurement and accounting would 
occur with the implementation of its Integrated Financial System. We 
will evaluate the effectiveness of IRS’s efforts during our fiscal year 
2002 financial audit. 

IRS Needs Records to Adequately Account for and Manage Software: 

During our fiscal year 2001 audit, we found that IRS’s property 
management system did not capture information, such as the licenser, 
contract period, and number of authorized users essential to ensure 
that software and software licenses are controlled and utilized in 
accordance with software license contracts. The Joint Financial 
Management Improvement Program (JFMIP) Property Management Systems 
Requirements state that property management systems should capture 
information essential to ensuring that software and software licenses 
are controlled and in compliance with contractual licenses and 
agreements with software developers, vendors, or software licensers. 

IRS’s property management system did not provide an inventory of the 
number of software licenses or the number of software installations. To 
properly account for compliance with software license agreements, IRS 
must determine if the number of installations exceeds the number of 
licenses. IRS is in the process of identifying the number of software 
licenses to record in its property management system. However, as of 
the end of our audit, IRS had not yet recorded software licenses in its 
property management system nor had it developed an approach to assess 
if the number of installations are in compliance with the terms of 
these software licenses. 

Recommendations: 

We recommend that you direct IRS management to: 

* record software licenses in IRS’s property management system, and; 

* develop an approach to assess IRS’s compliance with the terms of these
software licenses. 

IRS’s Comments and Our Evaluation: 

In its comments, IRS stated that it agreed with our recommendations. 
IRS stated that it is executing an action plan that will allow it to 
record existing software data into its property management database and 
establish a process that will inform the Asset Management office of new 
licenses purchased so they can be recorded within established 
timeframes. IRS stated that it is also developing an action plan that 
will set procedures and policies for the review and compliance to the 
terms of the licenses. We will evaluate the effectiveness of IRS’s 
efforts during our fiscal year 2002 financial audit. 

IRS Needs to Review and Properly Adjust Receivables in Its Accounting 
Records: 

During our fiscal year 2001 audit, we continued to find control 
weaknesses over IRS’s accounting for reimbursable activities, which 
resulted in IRS overstating its receivables for reimbursable 
activities. During fiscal year 2000, we reported that the records IRS 
maintained regarding reimbursable receivables were not reliable. 
[Footnote 17] We recommended IRS routinely review and age open 
reimbursable receivables to identify accounts that are no longer valid 
or collectible. During fiscal year 2001, we did find that IRS began 
aging accounts for the purpose of writing off older transactions and
that IRS revised loss percentages that it applied to receivable 
accounts to determine the net realizable value of these receivables. 
However, we found that IRS was still reporting reimbursable receivable 
amounts that were not valid receivables or that should have been 
written off as uncollectible. 

GAO’s Standards for Internal Control in the Federal Government states 
that internal controls should generally be designed to assure that 
ongoing monitoring occurs in the course of normal operations. This 
includes regular management and supervisory activities, comparisons, 
reconciliations, and other actions people take in performing their 
duties. Monitoring of receivables would include assessing receivables to
determine both the accuracy of the recorded balance and the potential 
to collect the balance. 

We tested a nonrepresentative selection of the five largest 
reimbursable receivables at the end of fiscal year 2001 and found 
exceptions involving two of the accounts. Specifically, we found that 
one of these accounts was not a valid receivable at fiscal year end, 
and the other receivable was not collectible and should therefore have 
been written off. 

In the first instance, IRS improperly reported as receivables $711,000 
of fees charged to taxpayers for photocopying tax documents. IRS staff 
at service center campuses had collected these fees when services were 
provided and had recorded the collections in the IRS custodial 
accounting general ledger. IRS’s general ledger system comprises both 
an independent administrative and a custodial general ledger that are 
not integrated with each other nor with their supporting records for 
material balances. Service center campus staff reported the revenue of 
the photocopy fees from the custodial general ledger to the 
administrative accounting staff prior to the closing of the accounting 
records at fiscal year end. However, the actual transfer of funds from 
the custodial system to the administrative accounting general ledger did
not take place until after the end of the fiscal year. When IRS’s 
administrative accounting staff recorded the fees in the administrative 
general ledger to recognize the revenue in the proper period, they 
recorded them as uncollected fees as of fiscal year end. As a result, 
the amount was erroneously included in the financial statements as a 
receivable. 

In the second instance, IRS reported in its fiscal year 2001 financial 
statements a receivable totaling $405,000 that represented an 
outstanding charge that had been disputed by another government agency. 
IRS had billed and collected $2.1 million from the agency for services 
provided by IRS staff. However, the agency disputed $405,000 of the 
billed amount and initiated actions to reclaim the disputed amount. 
Based on actions by the agency, Treasury applied the $405,000 of 
charges against the IRS Treasury account and IRS agreed the amount was 
not collectible. Nonetheless, it was erroneously reported as a fully 
collectible receivable in IRS’s financial statements. IRS noted that 
the methodology it uses to recognize uncollectible amounts resulted in 
the actual overstatement of receivables at fiscal year end being 
$243,000. 

Recommendation: 

In addition to fully implementing our previous recommendations 
regarding more effective review of reimbursable receivables, [Footnote 
18] we recommend that you direct IRS management to ensure that, in the 
absence of an integrated general ledger system for IRS’s custodial and 
administrative activities, IRS strengthen monitoring and analysis of 
receivables to ensure that receivables are not being erroneously 
recorded as a result of the lack of integration between these two 
activities. 

IRS’s Comments and Our Evaluation: 

In its comments, IRS stated that it agreed with our recommendation and 
that it is taking steps to better manage reimbursable activity. IRS 
noted for example, that it is now reconciling all reimbursable 
receivable accounts with the appropriate general ledger accounts 
monthly and is monitoring activities between custodial and 
administrative accounts as part of this reconciliation process. 
Additionally, IRS noted that it has implemented a process to routinely 
review open receivables and take action to write off amounts as 
appropriate. We will evaluate the effectiveness of IRS’s efforts during 
our fiscal year 2002 financial audit. 

IRS Needs to Develop Procedures to Estimate and Accrue Operating 
Revenue and Expenses: 

During our fiscal year 2001 financial audit, we noted that IRS 
continued to record material administrative transactions only at the 
end of the fiscal year. IRS’s imputed costs [Footnote 19] and other 
benefit-related expenses are determined by other federal agencies, and 
IRS is informed of the annual amount only at the end of the fiscal 
year. In addition, its administrative operations receive exchange 
revenues from installment agreements and other types of user fees and 
these amounts are also recorded in the administrative accounts as 
exchange revenue only at the end of the fiscal year. IRS does not have 
a methodology for identifying operating activities and estimating 
reasonable monthly accruals for recognizing costs and exchange revenues 
for its administrative operations at interim periods. As a result, 
IRS’s financial records for these activities were misstated at interim 
periods and the significance of these misstatements increases over the 
course of the fiscal year until IRS records these transactions at the 
end of the fiscal year. 

GAO’s Standards for Internal Control in the Federal Government requires 
agencies to implement internal control procedures to ensure ongoing 
reliability of its financial reporting. The standards also require that 
transactions be promptly recorded to maintain their relevance and value 
to management in controlling operations and making decisions. 
Additionally, for fiscal year 2002, OMB Bulletin 01-09, Form and
Content of Agency Financial Statements, requires agencies to report 
interim financial statements for the 6-month period ending March 31, 
2002. 

Even though IRS could readily estimate the annual amount of imputed 
costs and prepare monthly accruals, it did not have procedures for 
doing this during fiscal year 2001. Specifically, we found that imputed 
costs on IRS’s general ledger were understated by $406 million until 
IRS made an adjusting entry after September 30, 2001. In addition, 
employee benefit payment expenses were understated by $73 million until 
IRS made a year-end adjusting entry. Exchange revenues for its 
administrative operations were also understated at interim periods 
because these revenues were not being estimated and accrued regularly 
in the administrative operations financial records when the amounts to 
accrue were readily available. Exchange revenues totaling over $108 
million were not recognized in the administrative accounting records 
until the end of the fiscal year. These revenues related primarily to 
user fees for the processing of installment agreements and reviews of 
exempt organizations/employer benefit plans. 

Had IRS prepared interim financial statements during fiscal year 2001, 
the effect of these omissions described above would have been interim 
information that contained material misstatements for net cost and 
exchange revenue. Until IRS establishes procedures for estimating and 
accruing imputed administrative costs and exchange revenues, it will 
not be able to produce reliable interim financial information. We have 
made recommendations to address this weakness in our previous report 
[Footnote 20] and thus we are not making any new recommendations. 
However, we wanted to bring to your attention the significance of this 
matter in light of the fiscal year 2002 requirement under OMB Bulletin 
01-09. 

IRS’s Comments and Our Evaluation: 

In its comments, IRS agreed that it needs to estimate and accrue 
operating expenses in a timely manner. IRS stated that it began 
recording quarterly expense accruals in fiscal year 2002. Additionally, 
IRS stated that in fiscal year 2002, it began recording actual 
quarterly user fee revenues in its administrative accounts. We will 
evaluate the effectiveness of IRS’s efforts during our fiscal year 2002 
financial audit. 

This report contains recommendations to you. The head of a federal 
agency is required by 31 U.S.C. 720 to submit a written statement on 
actions taken on these recommendations. You should submit your 
statement to the Senate Committee on Governmental Affairs and the House 
Committee on Government Reform within 60 days of the date of this 
report. A written statement must also be sent to the House and Senate 
Committees on Appropriations with the agency’s first request for 
appropriations made more than 60 days after the date of the report. 

This report is intended for use by the management of IRS. We are 
sending copies to Chairmen and Ranking Minority Members of the Senate 
Committee on Appropriations; Senate Committee on Finance; Senate 
Committee on Governmental Affairs; Senate Committee on the Budget; 
Subcommittee on Treasury and General Government, Senate Committee on 
Appropriations; Subcommittee on Taxation and IRS Oversight, Senate 
Committee on Finance; and the Subcommittee on Oversight of Government 
Management, Restructuring, and the District of Columbia, Senate 
Committee on Governmental Affairs. We are also sending copies to the 
Chairmen and Ranking Minority Members of the House Committee on 
Appropriations; House Committee on Ways and Means; House Committee on 
Government Reform; House Committee on the Budget; Subcommittee on 
Treasury, Postal Service, and General Government, House Committee on 
Appropriations; Subcommittee on Government Efficiency, Financial 
Management, and Intergovernmental Relations, House Committee on 
Government Reform; and the Subcommittee on Oversight, House Committee 
on Ways and Means. In addition, we are sending copies of this report to
the Chairman and Vice-Chairman of the Joint Committee on Taxation, the 
Secretary of the Treasury, the Director of the Office of Management and 
Budget, the Chairman of the IRS Oversight Board, and other interested 
parties. Copies will be made available to others upon request. The 
report is also available on GAO’s internet homepage at [hyperlink, 
http://www.gao.gov]. 

We acknowledge and appreciate the cooperation and assistance provided 
by IRS officials and staff during our audit of IRS’s fiscal year 2001 
and 2000 financial statements. If you have any questions or need 
assistance in addressing these matters, please contact Charles Payton, 
Assistant Director, at (213) 830-1084. 

Sincerely yours, 

Signed by: 

Steven J. Sebastian: 
Director: 
Financial Management and Assurance: 

[End of correspondence] 

Enclosure I: 

Department Of The Treasury: 
Internal Revenue Service: 
Deputy Commissioner: 
Washington, D.C. 20224: 

June 20, 2002: 

Mr. Steven J. Sebastian: 
Acting Director: 
Financial Management and Assurance: 
U.S. General Accounting Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Sebastian: 

I am responding to your draft of the FY 2001 management letter 
entitled, Management Letter: Improvements Needed in IRS's Accounting 
Procedures and Internal Controls. 

I agree we need to continue to improve accounting procedures and 
internal controls. In fact, management has already begun addressing 
several of the areas your recommendations cover. However, I disagree, 
in part, with some of the issues you raised. The following are our 
specific comments on each recommendation. 

Recommendation: We recommend that you direct IRS management to develop 
and implement policies and procedures to require that field office 
employees provide taxpayer receipts for all walk-in payments; field 
offices post signs in the most visible locations to remind taxpayers to 
obtain receipts for payments; two employees be present when payments 
are collected and logged from drop boxes; IRS and lockbox employees 
performing final candling record receipts in a control log at the time 
of discovery, recording at a minimum the total number of payments 
found, the amount of each payment, and the taxpayer who submitted the 
payment; and IRS and lockbox managers or designated officials reconcile 
logs of payments found during final candling to the related receipts 
and documents. 

We also recommend that you direct IRS headquarters management to ensure 
that field office management comply with existing receipt control 
policies that require a segregation of duties between employees who 
prepare control logs for walk-in payments and employees who reconcile 
the control logs to the actual payments. 

Comments: We have taken the following corrective actions to address 
this finding: 

1) Revised Document 10161 to indicate a receipt is available upon 
request and posted signs in all Taxpayer Assistance Centers (TAC) or 
field offices notifying taxpayers that they can request a receipt. 

2) Distributed to TAC sites or field offices a procedural memo 
outlining separation of duties to emphasize the need to have more than 
one employee process drop box payments. 

3) Established a task force to develop procedures to reconcile payment 
logs. We expect to issue procedures to TAC or field offices by October 
1, 2002. SB/SE will work with W&l to ensure we include these changes in 
Lockbox Processing Guidelines for January 2003. This will also be an 
agenda item for discussion at the 2002 Lockbox Conference in August 
2002. 

Recommendation: We recommend that you direct IRS headquarters 
management to clarify that the intent of the requirement for background 
investigations is meant to apply to personnel being entrusted with 
taxpayer receipts and information rather than just personnel being 
granted access to an IRS facility. 

Comments: [See comment 1] We disagree with GAO's finding that IRS 
service centers did not verify that couriers transporting bank deposits 
were insured. The IRS has always required courier service employees to 
be licensed, insured, or bonded. However, we agree that courier service 
employees should undergo background checks. We are working with FMS to 
modify courier service contracts. For example, we will amend IRM 
3.8.45, Campuses Deposit Activity, courier service minimum requirements 
(effective August 1, 2002) to include the following language: 

A. Courier Service 

Shall ensure that courier service employees designated to transport 
Internal Revenue Service deposits and/or requiring access to Internal 
Revenue sites satisfy the requirements for a Basic Investigation, which 
includes a FBI Fingerprint and Name check, as defined in IRM 
1.23.2.2.8.1.1. 

Recommendation: We recommend that you direct IRS management to work 
with the National Finance Center (NFC) to resolve the technical 
limitations that exist within the SETS database and continue to 
periodically review SETS data to detect and correct errors. 

Comments: All NFC contact is facilitated through the Office of Human 
Resource Enterprise Systems (OHRES), Department of the Treasury. We 
will prepare a letter for the Chief, Agency-Wide Shared Services' 
signature addressed to the Director, OHRES requesting assistance to 
establish a dialogue with NFC to address SETS issues. The goal of this 
action is to make SETS a better tool for tracking fingerprints and 
background investigations. We will submit the letter to Treasury by 
June 28, 2002. 

Personnel offices must review SETS data monthly and ensure its accuracy 
and compliance with IRS' fingerprint policies. We concluded three days 
of personnel training on June 6, 2002, that focused on managing the 
fingerprint and background investigation program and devoted a module 
to analyzing SETS data. All 23 personnel offices were represented, with 
approximately 40 individuals in attendance. 

Recommendation: We recommend that you direct IRS management to issue a 
formal reminder of existing IRS manual refund procedures to supervisors 
and staff. 

Comments: We issued an Information Alert on December 6, 2001, with the 
following procedures: 

W&I or SB/SE (depending on the taxpayer) will monitor all manual 
refunds to ensure we issue no duplicate refunds and post the manual 
refund, and will document the monitoring actions. Management will 
review and document their review to ensure monitoring for duplicate 
refunds is ongoing until the manual refund posts to the applicable 
account. 

Recommendation: We recommend that you direct IRS management to 
establish procedures to track the release of liens up to the point of 
delivery to the local jurisdiction to ensure liens are released timely 
to avoid unduly burdening the taxpayer once they have satisfied their 
tax liability. 

Comments: We agree that failure to timely release liens can cause undue 
hardship and additional burden on taxpayers. We also agree procedures 
should include monitoring the mailing of certificates of release after 
the Automated Lien System (ALS) generates the certificate. 

Our ALS units normally print and mail certificates of release. Some 
locations are able to electronically transmit liens and releases to the 
recording official, a process that works efficiently and with little 
delay. In those locations requiring manual processing of paper 
documents, we have determined that our offices mail certificates of 
release at least weekly. Some offices mail these certificates daily. We 
not only depend on our own procedures for mailing but we also depend 
upon the United States Postal Service (USPS) to deliver the release to 
the recording jurisdictions within established timeframes. We also 
depend on the recording jurisdiction to record certificates of release 
promptly after receipt. 

We accept full responsibility for generating certificates of release 
and transmitting them to the appropriate recording official, by mail or 
electronic transfer, within the timeframes established by law. To 
further ensure we accomplish these actions within established 
timeframes, including document mailing, we are formulating procedures 
requiring a date stamp (mailing date) on the billing voucher. This 
document lists each release we send to the recording official. When we 
issue these procedures to the field, we will re-emphasize the need to 
timely accomplish all other processing steps. 

We believe these procedures will further reduce taxpayer burden. Those 
processes outside the IRS' control (USPS and recording jurisdictions) 
continue to add risk and contribute to additional taxpayer burden. 

Recommendation: We recommend that you direct IRS management to ensure 
that complete skeletal records are created and available for the SPIF 
units to update upon receipt of P&E, and develop and implement 
procedures and edit checks to reduce the likelihood of invalid property 
records. 

Comments: We agree with this recommendation and are developing 
requirements to implement an Electronic Packing Slip to address it. We 
will require vendors to forward, in an electronic format, specific 
information pertaining to equipment purchases at the time of shipment. 
We will use this information to build the skeletal records prior to the 
equipment arriving on site. In conjunction with this effort, we are 
developing policies and procedures to track these skeleton records and 
follow up with appropriate sites after a determined length of time to 
ensure timeliness of record updates. We will include these procedures 
in the IRM. In addition, we are currently reviewing the database for 
data anomalies and following up with appropriate areas for corrections. 
This also triggers process and procedural improvements to prevent 
future anomalies. We are also expanding our use of Network monitoring 
tools to track asset activity and are refining transactional business 
rules to enhance and tighten data validation prior to its entry into 
the database. Shortly, we will have the capability to implement mass 
updates of asset transactions. 

Recommendation: We recommend that you direct IRS management to develop 
and implement procedures to ensure that procurement award and 
requisition numbers recorded on property records are complete, 
accurate, and linked to the accounting records. 

Comments: We agree with this recommendation. The Electronic Packing 
Slip mentioned above will also require vendors to include requisition 
and procurement numbers of equipment purchases at the time of shipment. 
We will use this information to build the skeletal records prior to the 
equipment arriving on site. Full integration of inventory procurement 
and accounting will occur with the implementation of the Integrated 
Financial System. 

Recommendation: We recommend that you direct IRS management to record 
software licenses in IRS' property management system, and develop an 
approach to assess IRS's compliance, with the terms of these software 
licenses. 

Comments: We agree with this recommendation. We are executing an action 
plan that will allow us to populate the existing software data into the 
Information Technology and Asset Management Systems (ITAMS) database. 
Included in this action plan is the repeatable process that will inform 
the Asset Management office of new licenses as we purchase them so we 
can include them in the database within established timeframes. We are 
also developing an action plan that will set procedures and policies 
for the review and compliance to the terms of the licenses. 

Recommendation: In addition to fully implementing our previous 
recommendations regarding more effective review of reimbursable 
receivables, we recommend that you direct IRS management to ensure 
that, in the absence of an integrated general ledger system for IRS's 
custodial and administrative activities, IRS strengthen monitoring and 
analysis of receivables to ensure that receivables are not being 
erroneously recorded as a result of the lack of integration between 
these two activities. 

Comments: We agree with your recommendation and have taken steps to 
better manage reimbursable activity. We are reconciling all 
reimbursable receivable accounts with the appropriate general ledger 
accounts monthly. We are monitoring activities between custodial and 
administrative accounts as part of this reconciliation process. This 
reconciliation process will ensure that we do not reflect intra-agency 
transfers as receivables from an outside party. We now have a process 
in place to routinely review open receivables and take action to write 
off amounts as appropriate. We are also developing and testing new AFS 
transactions to properly record activity affecting prior year accounts, 
which was the cause of the overstatement of the two specific 
reimbursable receivables identified in your FY 2001 audit. 

Recommendation: GAO did not cite a specific new recommendation relative 
to IRS's need to develop procedures to estimate and accrue operating 
revenue and expenses. However, they did note that they have made 
recommendations on this topic in the past and the importance of 
addressing this issue in light of the need to prepare interim financial 
reports. 

Comments: We agree we must estimate and accrue operating expenses in a 
timely manner. The ultimate goal is to accrue monthly during the year. 
We began recording quarterly accruals for actuarial FECA (worker's 
compensation), accrued annual leave, and imputed interest costs in FY 
2002 and plan to do so monthly in the near future. We disagree that we 
should estimate revenue from user fees and record it on a pro forma 
basis during the year. In FY 2002, we began recording actual revenues 
from user fees in our administrative accounts quarterly. 

I appreciate your input and will continue to take the necessary steps 
to improve our financial management. With the continued dedication and 
cooperation of both our staffs, we will further enhance accounting 
procedures and internal controls. 

Sincerely, 

Signed by: 

Bob Wenzel: 

[End of letter] 

The following is GAO’s comment on the Internal Revenue Service’s letter 
dated June 20, 2002. 

GAO Comment: 

1. We have deleted material on this topic from our report. 

[End of enclosure] 

Enclosure II: 

GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Ted Hu, (213) 830-1108: 
David Elder, (213) 830-1112: 

Acknowledgments: 

Staff making key contributions to this report were: Beverly Burke, 
Gloria Cano, William Cordrey, John Davis, Charles R. Fox, Meafelia 
Gusukuma, Eric D. Johns, George Jones, Delores Lee, Angel Sharma, and 
Leonard Zapata. 

[End of enclosure] 

Footnotes: 

[1] U.S. General Accounting Office, Financial Audit: IRS’s Fiscal Year 
2001 and 2000 Financial Statements, GAO-02-414 (Washington D.C.: Feb. 
27, 2002). 

[2] IRS provides goods and services to federal agencies, state and 
foreign governments, and private organizations on a reimbursable cost 
basis. Payments due to IRS for these activities are referred to as 
reimbursable receivables. 

[3] GAO-02-414. 

[4] U.S. General Accounting Office, Internal Revenue Service: Physical 
Security Over Taxpayer Receipts and Data Needs Improvement, GAO/AIMD-99-
15 (Washington D.C.: Nov. 30, 1998); U.S. General Accounting Office, 
Internal Revenue Service: Custodial Financial Management Weaknesses, 
GAO/AIMD-99-193 (Washington D.C.: Aug. 4, 1999); U.S. General 
Accounting Office, Internal Revenue Service: Recommendations to Improve 
Financial and Operational Management, GAO-01-42 (Washington D.C.: Nov. 
17, 2000); and U.S. General Accounting Office, Internal Revenue 
Service: Progress Made, but Further Actions Needed to Improve Financial 
Management, GAO-02-35 (Washington D.C.: Oct. 19, 2001). 

[5] Walk-in taxpayers are individual taxpayers who choose to conduct 
business with IRS in person. Generally, these individuals are directed 
to the IRS field offices which have units set up to handle questions 
and accept payments from such taxpayers. 

[6] Final candling occurs at the end of the mail extraction process. 
After contents from envelopes are extracted, IRS staff illuminate, or 
“candle” all envelopes which have already gone through the extraction 
process to ensure that all contents are actually removed prior to
the envelopes’ destruction. 

[7] A lockbox refers to a commercial bank with a designated post office 
box to which taxpayers are instructed to mail their payments and 
related tax documents. These lockbox banks process the documents, 
deposit the payments, then forward the documents and data to IRS 
service center campuses to update the taxpayers’ accounts. Treasury’s 
Financial Management Service (FMS) has agreements with nine lockbox 
bank locations on IRS’s behalf. 

[8] GAO/AIMD-99-15, GAO/AIMD-99-193, GAO-01-42, and GAO-02-35. 

[9] U.S. General Accounting Office, Internal Revenue Service: Immediate 
and Long-Term Actions Needed to Improve Financial Management, GAO/AIMD-
99-16 (Washington D.C.: Oct. 30, 1998) and GAO-01-42. 

[10] IRS issues most refunds through an automated system; however, 
refunds meeting certain criteria are separated for manual processing, 
including (1) refunds over $1 million, (2) refunds below $1, and (3) 
refunds based on a taxpayer’s request for immediate payment due to 
hardship. 

[11] The master file is a detailed database containing taxpayer 
information. 

[12] IRS uses ALS to issue and release federal tax liens. ALS is 
updated for new liens and tax accounts by revenue officers at IRS’s 
field offices. ALS generates a certificate of release of lien 
automatically for liens that expire after a set period of time or when 
the statutory collection period for an account expires. For accounts 
that are fully paid or otherwise satisfied, ALS generates the 
certificate of release of lien only after it receives the “fully paid”
status of the account through a weekly interface with the master file. 
The certificate of release of lien is sent to the county courthouse 
where the lien was originally filed for formal release of the lien. 

[13] We are 95 percent confident that the confidence interval around 
this estimate ranges from 3 to 19 percent. 

[14] GAO-02-414. As explained in this report, in a book-to-floor 
sample, we were unable to locate 25 of 210 recorded assets and 
concluded that IRS’s P&E records were not adequate to maintain 
accountability over its property. 

[15] For our floor-to-book sample, we obtained a representative 
selection of P&E items with a two-stage cluster sample. In the first 
stage, we selected a representative sample of 21 buildings. In the 
second stage, we selected a sample of 10 assets located at each of the 
21 buildings and traced them to the inventory records. 

[16] In some cases, sample transactions, which are disbursement 
amounts, were payments for multiple P&E items. For example, one sample 
transaction totaling $466,020 was a disbursement for purchase of 180 
computers with keyboards, mouses, and monitors. 

[17] U.S. General Accounting Office, Management Letter: Improvements 
Needed in IRS’ Accounting Procedures and Internal Controls, GAO-01-880R 
(Washington D.C.: July 30, 2001). 

[18] GAO-01-880R. 

[19] Imputed costs are IRS costs that have been paid in part or in full 
by other entities. 

[20] GAO-02-35. 

[End of section] 

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